Office of Personnel Management
Retirement Systems Modernization Program Faces Numerous Challenges Gao ID: GAO-05-237 February 28, 2005The Office of Personnel Management (OPM) manages the systems that process retirement benefits for most federal civilian employees. In fiscal year 2003, over 198,000 claims were processed and over $50 billion in benefits was paid through OPM's retirement systems. OPM is trying to modernize these systems through a program called Retirement Systems Modernization (RSM). The conference report accompanying the fiscal year 2004 OPM appropriations act directed us to review the management of and challenges facing RSM. Specifically, our objectives were to determine (1) the current status of and plans for OPM's RSM program and (2) the challenges OPM faces in successfully managing the program.
The Office of Personnel Management (OPM) is in the midst of an effort known as Retirement Systems Modernization (RSM). OPM's goals, through this program, are to improve customer service, reduce calculation errors, and reduce the amount of paper-based and manual processing. OPM expects RSM's total cost to be about $294 million from fiscal year 1997 to fiscal year 2008, when the agency expects to have most of RSM implemented and integrated. As currently envisioned, RSM comprises four major components: licensed technology for pension benefits administration, data conversion of paper files and development of electronic processes for capture and storage of data, coverage determination and other applications, and foundation and infrastructure elements. GAO's experience with major systems acquisitions such as RSM has shown that having sound systems acquisition, change management, and investment management processes in place increases the likelihood of the acquisitions meeting cost and schedule estimates as well as performance requirements. However, GAO found that many of the processes in these areas for RSM are not sufficiently developed, are still under development, or are planned for future development. For example, OPM lacks needed processes for developing and managing requirements, planning and managing project activities, managing risks, and providing sound information to investment decision makers. Without these processes in place, RSM is at increased risk of not being developed and delivered on time and within budget and falling short of promised capabilities.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-237, Office of Personnel Management: Retirement Systems Modernization Program Faces Numerous Challenges
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Report to Congressional Committees:
February 2005:
Office of Personnel Management:
Retirement Systems Modernization Program Faces Numerous Challenges:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-237]:
GAO Highlights:
Highlights of GAO-05-237, a report to congressional committees
Why GAO Did This Study:
The Office of Personnel Management (OPM) manages the systems that
process retirement benefits for most federal civilian employees. In
fiscal year 2003, over 198,000 claims were processed and over $50
billion in benefits was paid through OPM‘s retirement systems. OPM is
trying to modernize these systems through a program called Retirement
Systems Modernization (RSM).
The conference report accompanying the fiscal year 2004 OPM
appropriations act directed us to review the management of and
challenges facing RSM. Specifically, our objectives were to determine
(1) the current status of and plans for OPM‘s RSM program and (2) the
challenges OPM faces in successfully managing the program.
What GAO Found:
The Office of Personnel Management (OPM) is in the midst of an effort
known as Retirement Systems Modernization (RSM). OPM‘s goals, through
this program, are to improve customer service, reduce calculation
errors, and reduce the amount of paper-based and manual processing. OPM
expects RSM‘s total cost to be about $294 million from fiscal year 1997
to fiscal year 2008, when the agency expects to have most of RSM
implemented and integrated. As currently envisioned, RSM comprises four
major components: licensed technology for pension benefits
administration, data conversion of paper files and development of
electronic processes for capture and storage of data, coverage
determination and other applications, and foundation and infrastructure
elements (see table).
GAO‘s experience with major systems acquisitions such as RSM has shown
that having sound systems acquisition, change management, and
investment management processes in place increases the likelihood of
the acquisitions meeting cost and schedule estimates as well as
performance requirements. However, GAO found that many of the processes
in these areas for RSM are not sufficiently developed, are still under
development, or are planned for future development. For example, OPM
lacks needed processes for developing and managing requirements,
planning and managing project activities, managing risks, and providing
sound information to investment decision makers. Without these
processes in place, RSM is at increased risk of not being developed and
delivered on time and within budget and falling short of promised
capabilities.
Major Components of RSM and Current Status and Plans:
RSM components and descriptions: Licensing technology–licensing a
pension administration system from a private vendor to process claims
and customer service inquiries;
Status and plans: Issued request for proposals in late September.
Contract award was expected by the end of January 2005. However, since
our briefing, the award has been delayed pending review by Office of
Management and Budget. Initial deployment planned for 2006.
RSM components and descriptions: Data conversion–includes selecting a
vendor to convert paper-based retirement information to an electronic
format and developing processes to electronically capture and store
incoming retirement information;
Status and plans: Separate request for proposals for conversion of
paper data to be issued before September 2005.
RSM components and descriptions: Coverage determination and other RSM
applications–includes developing an application to help determine
benefit amounts;
Status and plans: Pilot tested application in 2004. Plan is to fully
deploy governmentwide by February 2005.
RSM components and descriptions: Foundation and infrastructure
elements–developing the infrastructure and shared services to support
RSM;
Status and plans: Maintaining and developing master database of
retirement information to support licensed technology. Developing
infrastructure to support data transmission between OPM and other
agencies.
Source: GAO.
[End of table]
What GAO Recommends:
GAO is recommending that the director of OPM ensure that the RSM
program office establish the management processes needed for effective
oversight of the RSM program.
In written comments on a draft of this briefing, the OPM director
agreed that the management processes we identified are essential and
described steps the agency is taking to strengthen these processes.
www.gao.gov/cgi-bin/getrpt?GAO-05-237.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact David Powner at (202) 512-
9286 or pownerd@gao.gov.
[End of section]
Contents:
Letter:
Recommendations:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Briefing Slides:
Appendix II: Comments from the Office of Personnel Management:
Abbreviations:
OPM: Office of Personnel Management:
RSM: Retirement Systems Modernization:
Letter February 28, 2005:
The Honorable Thad Cochran:
Chairman:
The Honorable Robert C. Byrd:
Ranking Minority Member:
Committee on Appropriations:
United States Senate:
The Honorable Jerry Lewis:
Chairman:
The Honorable David R. Obey:
Ranking Minority Member:
Committee on Appropriations:
House of Representatives:
The Office of Personnel Management (OPM) manages the systems that
process retirement benefits for most federal civilian employees. In
fiscal year 2003, over 198,000 claims were processed and over $50
billion in benefits was paid through OPM's retirement systems. OPM is
trying to modernize these systems through a program called the
Retirement Systems Modernization (RSM). OPM's goals, through this
program, are to improve customer service, reduce calculation errors,
and reduce the amount of paper-based and manual processing.
The conference report accompanying the fiscal year 2004 OPM
appropriations act[Footnote 1] directed us to review the management of
and challenges facing RSM. Specifically, our objectives were to
determine the following:
(1) What is the current status of and plans for OPM's RSM program?
(2) What challenges does OPM face in successfully managing the program?
To determine program status and plans, we analyzed current and past
program documents and interviewed program officials. To identify
program challenges, we identified sound information technology systems
acquisition and management processes from our prior work and from
industry standards. We compared OPM's processes for managing RSM to
sound management practices in key areas. We analyzed program
documentation and interviewed program officials regarding their efforts
and plans. We performed our work at OPM offices in Washington, D.C.,
from April through December 2004 in accordance with generally accepted
government auditing standards.
On December 8, 2004, we provided a detailed briefing to the relevant
subcommittee offices on the results of this work. The briefing slides
are included in appendix I. The purpose of this letter is to formally
publish the briefing slides and officially transmit our recommendations
to the director of OPM.
In brief, we reported that OPM expects RSM's total cost to be about
$294 million from fiscal year 1997 to fiscal year 2008. As currently
envisioned, RSM comprises four major components: licensed technology
for pension benefits administration, data conversion of paper files and
development of electronic processes for capture and storage of data,
coverage determination and other applications, and foundation and
infrastructure elements. OPM planned to award the contract for licensed
technology at the end of January 2005 and expects to have most of RSM
implemented and integrated by the end of fiscal year 2008.
After our briefing, the RSM project manager told us that the award of
the licensed technology contract had been delayed because the Office of
Management and Budget has asked to review a revised business case for
RSM before OPM awards the licensed technology contract.
OPM has implemented selected management processes; however, many
processes are not sufficiently developed, are still under development,
or are planned for future development. For example, OPM lacks needed
processes for developing and managing requirements, planning and
managing project activities, managing risks, and providing sound
information to investment decision makers. Without these processes in
place, the RSM program is at increased risk of not being developed and
delivered on time and within budget. It is also at risk of falling
short of promised capabilities.
Recommendations:
To address the challenges we identified, we are recommending that OPM
establish the processes needed for effective oversight of the program.
Before awarding a contract for the defined benefit technology portion
of RSM, we recommend that the director of OPM ensures that the RSM
program office performs the following:
* Conducts a detailed validation of OPM's previously developed
requirements, including examining each requirement to determine whether
it is mandatory or optional for the system. OPM should then use this
analysis during contract negotiations to ensure the best value in
awarding the contract.
* Develops project management processes for tracking cost, schedule,
and performance progress on RSM components against planned objectives.
We also recommend that the director of OPM ensure that the RSM program
office expeditiously performs the following:
* Develops an acquisition strategy that includes deliverables and
milestones throughout the entire project life cycle, addresses issues
related to the transition of the licensed technology to a fully
operational state, and addresses all major elements of RSM.
* Develops an acquisition strategy for the data conversion portion of
RSM that addresses interdependencies with the licensed technology
portion of RSM.
* Develops a list of critical interdependencies among the tasks in
different portions of RSM.
* Implements a comprehensive risk management program including
identification, tracking, and updating of programwide risks, and
conducts routine discussions of risk mitigation activities with senior
management.
We are also recommending that the director of OPM ensure that the RSM
program office expeditiously performs the following:
* Updates change management plans to reflect the current acquisition
approach. The plans should identify and address the tasks and
associated milestones needed to prepare users for the impact of the
system on their roles and responsibilities.
* Develops a comprehensive governance structure that includes
documented processes guiding the executive steering committee's
activities.
* Develops a detailed security plan and a set of security requirements
for the licensed technology and data conversion portions of RSM.
Agency Comments and Our Evaluation:
OPM provided written comments on a draft of this report, which are
included in appendix II. In the comments, the OPM director agreed that
the management processes we identified are essential to ensure that RSM
is accomplished on time, within budget, and meets its expectations of
improved customer service and efficiency. The OPM director also listed
several actions the agency has taken to strengthen management and
oversight of RSM. For example, OPM is using its project management
consultant to strengthen management processes, reporting and governance
structures, and risk management. For the data conversion portion of
RSM, OPM is also developing an acquisition strategy and stated that it
has completed requirements analysis, security, and risk mitigation
plans. OPM also stated it has recently hired an employee to lead
efforts to develop a change management plan for each portion of RSM
prior to implementation.
However, OPM reiterated that it had included mandatory business
requirements in the request for proposals for licensed technology and
that the remaining business requirements would be reviewed after
contract award to determine whether or not they should be adopted. As
we state in our briefing slides, our review of the request for
proposals and other program documentation does not indicate that OPM
has clearly documented the mandatory versus optional requirements. A
clear understanding of optional versus mandatory requirements is
critical to ensuring that the government obtains the best value in its
systems acquisitions. The licensed technology award has been delayed
due to OMB's request to review a revised business case. Therefore, OPM
has additional time to define its mandatory and optional requirements
as recommended so that it can select the vendor that can provide the
best solution at least cost.
We are sending copies of this report to the director of the Office of
Personnel Management and other interested parties. Copies will also be
made available to others on request.
Should you or your staffs have any questions concerning this report,
please contact me at 202-512-9286 or by e-mail at [Hyperlink,
pownerd@gao.gov]. Camille Chaires, Vijay D'Souza, Nancy Glover, Colleen
Phillips, and Sylvia Shanks were key contributors to this report.
Signed by:
David A. Powner:
Director, Information Technology Management:
[End of section]
Appendixes:
Appendix I: Briefing Slides:
Office of Personnel Management's Retirement Systems Modernization
Program Faces Numerous Challenges:
Briefing for the Subcommittee on Transportation, Treasury and General
Government:
Senate Appropriations Committee:
and:
The Subcommittee on Transportation, Treasury, and Independent Agencies:
House Appropriations Committee:
December 8, 2004:
* Objectives:
* Scope and Methodology:
* Results in Brief:
* Background:
* Retirement Systems Modernization Status and Plans:
* Retirement Systems Modernization Challenges:
-Systems Acquisition Management:
-Organizational Change Management:
-IT Investment Management:
-Information Security:
* Conclusions:
* Recommendations:
* Agency Comments and Our Evaluation:
Objectives:
The Office of Personnel Management (OPM) is modernizing the systems and
processes it uses to manage federal retirement benefits under a program
called Retirement Systems Modernization (RSM). The conference report
accompanying the fiscal year 2004 OPM appropriations act [NOTE 1]
directs GAO to review the management of and challenges facing RSM.
Specifically, our objectives are:
* What is the current status of and plans for OPM's RSM program?
* What challenges does OPM face in successfully managing the program?
Scope and Methodology:
To determine program status and plans, we analyzed current and past
program documents including plans, acquisition documents, deliverables,
and OPM analyses, and interviewed program officials.
To identify program challenges, we identified sound IT systems
acquisition and management processes from our prior work and industry
standards, such as those developed by the Software Engineering
Institute. [NOTE 2] Given RSM's current status and plans, we focused
our review on the following key processes:
Systems acquisition management:
* Acquisition planning-preparation for key activities related to
systems acquisition:
* Requirements development and management-elicitation, analysis,
validation, and management of customer and stakeholder needs:
* Project management-planning and managing project-related activities,
such as interrelation of components and tracking of cost and schedule:
* Program risk management-identification and mitigation of potential
project risks:
We also evaluated three management areas critical to the success of IT
modernization projects:
* Organizational change management-preparing users for business process
changes accompanying system implementation:
* IT investment management-providing oversight for the selection,
control, and evaluation of IT investments:
* Information security-protecting the integrity, confidentiality, and
availability of data by minimizing risks of unauthorized intrusions and
serious disruptions of operations.
We compared OPM's processes for managing RSM to sound management
practices in each of these areas. We analyzed program documentation and
interviewed program officials regarding their efforts and plans. We
also reviewed relevant work by GAO and OPM's Inspector General's office.
We performed our work at OPM offices in Washington, DC from April
through December 2004 in accordance with generally accepted government
auditing standards.
Results in Brief:
Status and Plans:
OPM is in the midst of an effort, known as the Retirement System
Modernization (RSM), to automate the processes and systems supporting
federal retirement programs. From 1997 to 2001, OPM spent about $12
million developing planning documents, strategies, and analyses to
build RSM.
In 2001, the agency changed direction on RSM to rely heavily on
licensing existing technology for administering pension benefits from
an outside vendor that would host and maintain a large part of RSM.
After the redirection, OPM estimated RSM's total cost to be about $282
million from fiscal year 2002 to 2008. As currently envisioned, RSM
comprises four major components: licensed technology for pension
benefits administration, data conversion of paper files, coverage
determination and other applications, and foundation and infrastructure
elements.
Results in Brief:
The major components of RSM and their current status and plans are:
RSM components and descriptions: Licensing technology--licensing a
pension administration system from a private vendor to process claims
and customer service inquiries;
Status and plans: Request for proposals issued in late September.
Contract expected to be awarded by the end of January 2005 and initial
deployment planned for 2006.
RSM components and descriptions: Data conversion--includes selecting a
vendor to convert paper-based retirement information to an electronic
format and developing processes to electronically capture and store
incoming retirement information;
Status and plans: Separate request for proposals for conversion of
paper data to be issued before September 2005.
RSM components and descriptions: Coverage determination and other RSM
applications--includes developing an application to help determine
benefit amounts;
Status and plans: Pilot tested the application in 2004. Plan is to
fully deploy governmentwide by February 2005.
RSM components and descriptions: Foundation and infrastructure
elements--developing the infrastructure and shared services to support
RSM;
Status and plans: Maintaining and developing master database of
retirement information to support licensed technology. Developing
infrastructure to support data transmission between other agencies and
OPM.
[End of table]
OPM expects to have most of RSM implemented and integrated by the end
of fiscal year 2008.
Challenges to RSM:
Our experience with major systems acquisitions has shown that having
sound systems acquisition, change management, and investment management
processes in place increases the likelihood of the acquisitions meeting
cost and schedule estimates as well as performance requirements.
OPM has implemented selected processes in the areas of systems
acquisition, change management, investment management, and information
security; however, many processes are not sufficiently developed, are
still under development, or are planned for future development. For
example, OPM lacks needed processes for developing and managing
requirements, planning and managing project activities, managing risks,
and providing sound information to investment decision makers. Without
these processes in place, RSM is at increased risk of not being
developed and delivered on time and within budget. It is also at risk
of falling short of promised capabilities.
To address these challenges, we are recommending that OPM establish the
processes needed for effective oversight of the program.
In reviewing a draft of our briefing, RSM program management staff
generally agreed with the facts and recommendations in our briefing and
provided technical corrections that we incorporated as appropriate.
Background:
Office of Personnel Management Mission:
OPM's mission is "to build a high quality and diverse federal
workforce, based on merit system principles, that America needs to
guarantee freedom, promote prosperity, and ensure the security of this
great nation". [NOTE 3]
One of OPM's major human resources tasks is to manage and administer
the federal retirement program:
* OPM's Center for Retirement and Insurance Services administers the
retirement program.
* In fiscal year 2003, OPM processed over 198,000 retirement annuity
and survivor claims.
* Federal agency staff, current federal employees, and those receiving
benefits (annuitants) rely on OPM's existing information systems and
processes to accurately provide services such as calculating benefit
amounts, processing contributions, and paying benefits.
Federal Retirement Systems:
OPM administers two retirement plans for federal employees:
The Civil Service Retirement System (CSRS)-CSRS provides retirement,
disability, and survivor benefits and is a stand-alone pension system
that covers most employees hired before 1984.
The defined benefit [NOTE 4] portion of the Federal Employees
Retirement System (FERS)-FERS is a 3-part retirement plan which
includes: 1) a defined benefit portion administered by OPM; 2) Social
Security; and 3) the Thrift Savings Plan, a defined contribution plan
administered by the Federal Retirement Thrift Investment Board. FERS
became effective January 1, 1987. [NOTE 5]
For fiscal year 2003:
* There were 2.6 million federal employees actively paying into the
retirement system.
* There were 2.4 million federal retirement annuitants.
* Over $50 billion was paid to annuitants, survivors, and families.
Over time, the number of FERS annuitants is expected to increase and
the number of CSRS annuitants is expected to decrease.
Figure 1: Annuitants and survivors in CSRS and FERS retirement systems:
[See PDF for image]
Source: GAO analysis based on OPM data.
[End of figure]
OPM has identified multiple factors that could limit its ability to
provide high-quality retirement services, including:
* the increasing number of FERS retirement claims, which are more
difficult to process than CSRS claims because of the complexity of FERS
calculations;
* the existing high error rate associated with the CSRS and FERS
benefit calculations, estimated by OPM at 11 percent of all claims;
and:
* the high cost, limited capabilities, and other problems with existing
OPM information systems and processes.
Retirement Systems Modernization Program:
Through RSM, OPM expects to reengineer the various processes that
provide services to retirement program participants and that support
benefits counseling throughout an employee's career with the federal
government.
Specifically, OPM's objectives for RSM are to:
* create a single, integrated data repository accessible to OPM and
agency personnel across all retirement programs,
* standardize applications for coverage and eligibility determinations
and benefits calculations, making them specific to customer needs and
accessible to federal agencies and program participants,
* automate the process of entering data into its systems,
* initiate electronic case management and workload planning,
* create Web-accessible, self-service applications for the
administration of retirement programs to members and appropriate on-
demand changes to employee or annuitant records, and:
* establish a comprehensive customer contact center.
OPM expects RSM to change the systems and processes used by all
agencies that have employees covered by retirement programs managed by
OPM. This constitutes the vast majority of federal civilian employees.
[NOTE 6]
To represent federal agencies and provide input to OPM on RSM
direction, priorities, and other topics, OPM created the Agency
Advisory Committee, which consists of members from the departments of
Agriculture, Defense, Labor, Treasury, and the U.S. Postal Service.
Retirement Systems Modernization Program:
RSM is not the first attempt to modernize OPM's retirement benefits
systems. In 1987, OPM began an effort called the FERS Automated
Processing System program. In September 1995, after 8 years of work and
an investment of about $25 million, OPM stopped working on the program
to conduct an internal progress review. [NOTE 7] The review found that:
* Despite 8 years of work, the program was at a high risk of failure.
* The program lacked important planning elements, such as a clear
strategic vision and definition of the relationship of the project to
overall agency information technology plans.
* The development process did not define adequate performance measures
and test and evaluation results.
* The agency had not defined clear incentives for the contractor.
* The program was unsuccessful in defining clear, traceable business
requirements and in implementing a change control process to track
changes in the requirements.
* OPM lacked an effective, documented IT management process that could
support such a large and complex program.
In 1996, as a result of the review, OPM terminated the FERS Automated
Processing System program.
According to agency officials, OPM was able to reuse some of the
investment in the FERS Automated Processing System. Specifically:
* OPM is using the hardware it purchased for the FERS Automated
Processing System program in its existing retirement systems.
* OPM also used information gathered for this program for background
and planning purposes for RSM.
* The lessons identified in the internal progress review were used to
establish management structures for RSM.
OPM began plans for RSM in 1997 and originally intended to manage the
system in house by purchasing and modifying hardware and existing
software packages. From 1997 to 2001, OPM spent about $12 million
developing planning documents, strategies, and analyses to deal with
operational changes that RSM would cause. The agency also began
developing security requirements and business requirements for RSM.
In 2001, OPM decided to change the direction of RSM. Specifically, OPM
examined the possibility of increasing the role of private vendors in
hosting and maintaining key components of RSM. After an initial
internal analysis, the agency issued a request for information in 2002
to private vendors regarding outsourcing key retirement program
functions. The analysis of responses to the request for information
showed:
* Viable outsourcing alternatives existed for OPM's retirement system
administration needs.
* The proposed solutions could be both cost efficient and less risky to
implement.
* The proposed solutions were more likely to be completed on time and
on budget.
As a result of these findings, OPM decided to license technology for
administering pension benefits (including functions such as claims
processing and customer service inquiries) from a vendor.
Given this change of direction, RSM now has four major components:
* Licensing technology-Licensing an existing defined benefit system
from a private company. Although OPM plans for the vendor to host and
maintain the system, OPM employees will continue to manage the work of
claims processing and customer service.
* Data conversion-Awarding a contract to convert existing paper-based
retirement information to an electronic format and developing processes
to electronically capture and store incoming retirement information.
* Coverage determination and other RSM applications-Developing
applications including one that helps human resources specialists at
federal agencies determine an employee's correct retirement coverage
using a series of automated rules and steps. The coverage determination
application is designed to reduce errors in benefit calculations.
* Foundation and infrastructure elements-Implementing the network
infrastructure, hardware, software, and other shared services to
develop and run RSM applications and meet federal and OPM information
technology standards. Examples include processes to support data
transmission from federal agencies and a database to support the
coverage determination application.
The RSM program office is managing the integration of the four
components. To assist in project management and technical support, OPM
hired two support contractors and has recently hired a project
management consultant.
RSM Status and Plans Overview:
Much of the work on RSM over the last 7 years has focused on planning
and preparation. Tasks completed to date include developing and issuing
a request for information to private vendors, developing a request for
proposals, and some application development work. Between 1997 and
September 2004, OPM has spent about $22 million for RSM, and plans to
spend about $272 million more to acquire, deploy, and operate the
system through 2008.
OPM is currently working on the following efforts:
* awarding a contract to license technology from a private company for
defined benefit administration,
* issuing a request for proposals for conversion of paper data,
* enhancing and deploying the coverage determination application, and:
* maintaining and enhancing the supporting hardware and network
infrastructure.
OPM expects to implement and integrate the majority of RSM components
by the end of fiscal year 2007 and add other applications in 2008.
RSM Status and Plans Costs:
RSM is expected to cost about $294 million between 1997 and 2008. OPM
spent about $12 million on planning for RSM between fiscal years 1997
and 2001. After deciding to license technology, OPM re-estimated RSM
costs as about $282 million from fiscal year 2002 to 2008. As of
September 2004, OPM has spent about $10 million of this amount. The
$282 million comprises the following:
Figure 2: Major costs for RSM components, fiscal years 2002-2008,
rounded to nearest million:
[See PDF for image] -graphic text:
Foundation and infrastructure elements: $26.
Coverage determination application and other RSM applications: $12.
Licensing technology: $128.
Data conversion and planning: $60.
Project management and other costs: $56.
Source: OPM.
[End of figure]
The status of major components of RSM as of October 2004 is as follows:
Licensing technology:
* OPM issued a draft request for proposals for licensing the defined
benefit technology in July 2004 and planned to award the contract by
December 2004.
* The final request for proposals was scheduled to be issued in mid-
August, but was not actually issued until late September.
* As a result, the deadline for vendor proposal submission, which was
originally September 10, was delayed to October 12.
* Agency officials said that the contract award, originally planned for
mid-December, is now planned for the end of January 2005.
Figure 3: Planned versus actual schedule for licensed technology
contract award:
[See PDF for image]
Source: OPM.
[End of figure]
* OPM still plans initial deployment of the licensed technology
component in 2006. Data conversion:
* In February 2004, OPM implemented electronic storage of retirement
information on federal employees whose agencies were transitioning to
the e-Payroll initiative. [NOTE 8] Previously, the agencies would have
had to print a paper retirement record for each employee that would
have then been entered into OPM's information systems.
* OPM is planning to issue a separate request for proposals for
conversion of paper data and select a vendor by September 2005.
Historical paper retirement data is planned to be converted by the end
of fiscal year 2007.
Coverage determination and other RSM applications:
* OPM piloted the coverage determination application earlier this year,
initially releasing it to a limited number of agencies and users. OPM
released the revised application in September 2004 and is planning to
fully deploy the application governmentwide by February 2005. Agency
officials estimated that there would be about 3,000 total application
users and that about 1,000 were using the system as of December 2004.
Foundation and infrastructure elements:
* OPM is implementing changes in its retirement systems infrastructure
to improve the ability of federal agencies to electronically transmit
retirement data to OPM. The infrastructure currently supports parts of
RSM, such as the coverage determination application and the transfer of
e-Payroll-related data, that are already in use. OPM plans to implement
additional changes and enhancements to its infrastructure to support
other parts of RSM as they are developed.
* OPM is also developing a master database to store all retirement data
for current active employees. According to RSM program officials, this
database supports the coverage determination application and certain
other applications. Next year, OPM is planning to enhance the database
to support the selected licensed technology solution.
OPM expects to have most of RSM implemented and integrated by the end
of fiscal year 2008.
RSM Challenges:
To effectively manage major IT programs, organizations can use sound
acquisition and management processes to minimize risks and thereby
maximize chances for success. Such processes have been identified by
leading organizations such as the Software Engineering Institute, the
CIO Council, and our prior work looking at best practices in industry
and government. Key areas include:
* Systems acquisition management-Management of cost, budget, and
schedule goals for information systems acquisition projects. Key
processes for systems acquisitions include acquisition planning,
requirements development and management, project management, and
program risk management.
* Organizational change management-Preparing users for business process
changes accompanying system implementation.
* IT investment management-Providing oversight for the selection,
control, and evaluation of IT investments.
* Information security-Protecting the integrity, confidentiality, and
availability of data by minimizing risks of unauthorized intrusions and
serious disruptions of operations.
Our work has shown that such processes are a significant factor in
successful systems acquisitions and development programs, and they
improve the likelihood of meeting cost and schedule estimates as well
as performance requirements.
RSM Challenges:
Systems Acquisition Management:
Acquisition planning:
According to leading IT organizations, acquisition planning involves
preparing for key activities, such as requirements definition and risk
management, and items such as budgeting, scheduling, and developing an
acquisition strategy. Effective acquisition planning includes having a
written organizational policy guiding acquisitions and an acquisition
strategy that includes objectives, projected costs and schedules,
risks, and addresses the entire project life cycle.
According to RSM program officials, OPM does not have an agency-wide
policy specific to IT acquisitions. Agency officials stated that RSM is
an unusually large program for OPM, and that they are developing plans
and processes based on a combination of OPM's general procurement
policy, IT development processes, and industry best practices. The
officials said that approval processes for IT acquisitions are defined
based on dollar amounts; however, they did not provide information
detailing criteria for evaluation of investments or written processes
guiding IT acquisitions.
While OPM has developed an acquisition strategy for the licensed
technology portion of RSM that provides objectives, estimated costs,
and a high-level discussion of risks, this plan is not sufficiently
detailed or comprehensive. Specifically, the strategy does not address
issues related to supporting the acquisition later in its life cycle,
including identifying the facilities and resources needed for support
of the licensed technology, any plans to transition the software from
the acquisition organization to a support organization, or planning for
long-term growth and supportability of the system. According to agency
officials, this information is contained in draft budget-related
documentation, which is not yet completed.
OPM also has not yet developed an acquisition strategy for the data
conversion portion of RSM or defined which deliverables are needed for
data conversion to test the defined benefit technology. Agency
officials said they plan to develop the acquisition strategy for data
conversion before issuing a request for proposals; however, they did
not provide a specific date for completion.
The lack of an agencywide policy for IT acquisitions increases the risk
that OPM will not be able to effectively manage RSM to deliver promised
capabilities on time and within cost estimates. This risk is more
significant given that agency officials acknowledge RSM is a large and
unique project for OPM. Further, the lack of a strategy to address
longer-term issues relating to the licensed technology acquisition
increases the risk that unforeseen issues could limit the ability of
the system to become fully operational. Without a developed acquisition
strategy that addresses all major elements of RSM, including data
conversion, the risk is also increased that interdependencies among the
different portions of RSM may not be identified and addressed early in
the acquisition.
Requirements development and management:
Leading IT organizations recognize the importance of requirements
development and management, including the elicitation, analysis, and
validation of customer and stakeholder needs and expectations. An
effective requirements management process involves establishing an
agreed-upon set of requirements and managing any changes to the
requirements in collaboration with stakeholders. In addition,
requirements that are mandatory versus optional should be defined and
used in deciding what requirements can be eliminated or postponed to
meet other project goals, such as cost and schedule constraints.
OPM created an extensive set of requirements when RSM development was
originally planned. However, much of the work involved in establishing
these requirements was performed four years ago and has not been
updated.
For the licensed technology portion of RSM, agency officials plan to
reevaluate the previously developed system requirements relating to
this portion of the project after contract award to see which
requirements are essential and which can be eliminated. Accordingly,
the winning vendor's solution may provide the essential requirements or
it may need to be customized at additional cost.
Agency officials told us that they believe that the functionality
provided by vendors for the licensed technology portion of RSM is
comparable and that similar amounts of customization would most likely
be required of all vendors. They believe this is true because none of
the potential vendors currently service federal customers and any
unique requirements would most likely be due to specific rules and
regulations of federal retirement programs. However, they did not
provide an analysis to support this statement.
If OPM does not determine its essential requirements before contract
award, the agency may not be able to select the vendor that can provide
the best solution at least cost. Based on its current approach, OPM
will not know the actual cost of licensing technology until after
contract award and the negotiation of customization costs with the
selected vendor.
Project management:
Effective project management is the process for planning and managing
all project-related activities, such as defining how components are
interrelated, defining tasks, estimating and obtaining resources, and
scheduling activities. Project management allows the performance, cost,
and schedule of the overall program to be continually measured,
compared with planned objectives, and controlled.
OPM has defined major components of RSM but it has not yet defined the
dependencies among tasks in the different portions of RSM.
Specifically, OPM does not yet have a plan that identifies critical
tasks in one area that will impact the completion of other tasks in the
program. For example, OPM has not defined the tasks from the data
conversion portion of the program that must be completed before the
licensed technology portion of RSM can be tested.
Additionally, OPM plans to develop key processes for managing and
tracking progress on RSM after awarding the defined benefit technology
contract.
* Agency officials said they want to develop processes that meet their
needs as well as the vendor's capabilities.
* OPM's request for proposals requires that vendors submit a proposed
project management plan and proposed performance standards, quality
levels, and monitoring methods. Agency officials said its negotiations
with vendors would include refining progress and quality metrics,
planned objectives, and control mechanisms.
Agency officials also stated that their recently hired project
management consultant will help develop project management tools;
however, they have not yet finalized the tasks the contractor will
perform.
By not identifying critical dependencies among tasks in RSM, OPM
increases the risk that unforeseen delays in one area of RSM will
hinder progress in other areas of RSM. Further, until it develops its
own initial set of project management processes and metrics, OPM
increases the risk that it will be unable to effectively oversee all
RSM components. It also increases the risk that the project metrics
ultimately negotiated with the vendor may not best meet the agency's
needs. As a result, RSM is more likely to exceed expected costs and
schedules.
Program risk management:
According to leading systems acquisition organizations, risk management
is a process for identifying potential problems before they occur and
adjusting the acquisition to decrease the chance of their occurrence.
Risks should be identified as early as possible and a risk management
process should be developed and put in place. Risks should be
identified, analyzed, mitigated, and tracked to closure.
RSM program staff develop an overall risk assessment annually as part
of the budgeting process. In addition, an RSM support contractor
maintains a database that tracks risks for each of the task orders they
receive. However, OPM officials acknowledged that they do not yet have
a process for identifying and tracking RSM programmatic risks, cross-
cutting issues, and mitigation strategies at regular meetings of
program officials.
In its request for proposals for the licensed technology, OPM has asked
each vendor to provide its own risk assessment and mitigation
strategies. OPM has also said its project management consultant will
assist it in implementing a program-wide risk management process;
however, exact milestones and tasks have not been finalized.
Until it establishes a formal program-wide risk management process to
track and manage risks and cross-cutting issues on an ongoing basis,
OPM does not have a mechanism to address unforeseen problems. Without
such a process, OPM faces potential RSM cost, schedule, and quality
control issues.
RSM Challenges:
Organizational Change Management:
According to leading IT organizations, organizational change management
is the process of preparing users for the business process changes that
will accompany implementation of the system. An effective
organizational change management process includes project plans that
prepare users for impacts the new system might have on their roles and
responsibilities and a process to manage those changes.
OPM officials stated that change management issues pose one of the most
substantial challenges to the success of RSM. These issues require
action within OPM and at other agencies with which OPM exchanges
information. To address change management, the agency has completed
several planning documents for RSM. However, many of these documents
were completed before OPM's 2002 decision to license technology from a
private vendor. OPM has not updated these plans to reflect its new
approach.
Further, OPM has not yet developed a detailed transition plan to help
prepare users for changes to their job responsibilities. Agency
officials said that they will develop a more detailed change management
plan after contract award for the licensed technology. However, they
have not yet identified tasks and milestones for completing this plan.
Our prior work has shown that addressing business process changes is
critical to the success of system modernization efforts. [NOTE 9] If a
comprehensive change management plan is not developed with user
involvement before the licensed technology is implemented, confusion
about roles and responsibilities could hinder effective implementation
of the system and limit the cost and quality improvements that OPM is
seeking.
RSM Challenges:
IT Investment Management:
The Office of Management and Budget and GAO guidance call for agencies
to establish IT investment management boards comprised of key
executives to regularly track the progress of major systems
acquisitions. These boards should have documented policies and
procedures for management oversight of IT projects and systems, and
should be able to adequately oversee projects' progress toward cost and
schedule milestones and their risks. The board should also employ early
warning systems that enable it to take corrective actions at the first
sign of cost, schedule, and performance slippages.
RSM has an executive steering committee chaired by the deputy associate
director of the Center for Retirement and Insurance Services that acts
as an IT investment management board for RSM. Currently, RSM program
officials meet quarterly with the executive steering committee to
discuss progress. However, RSM program officials were not aware of
formal policies or procedures guiding the board's oversight
responsibilities or activities. Agency officials stated that they will
define such a governance structure for the licensed technology portion
of RSM during the contract award process.
An undefined governance structure increases the risk that the executive
steering committee will not be able to effectively oversee and evaluate
RSM and track program status successfully. For example, the committee
may have difficulty monitoring accomplishment of mission requirements,
compliance with key program dates, and closure of risk items.
RSM Challenges:
Information Security:
Federal guidance and laws require that an agency's information systems
security activities include a security management plan and detailed
security requirements. In addition, systems should be certified and
accredited.
* The RSM project has an overall information security plan. In
addition, the RSM program office has developed an overall security and
privacy requirements plan that uses industry standard security controls
to ensure the protection of the sensitive user data that will be
processed by the systems.
* The Coverage Determination Application portion of RSM also has an
information security plan and has been certified and accredited, as has
the portion of RSM dealing with capture of e-Payroll data.
However, RSM is missing key required elements for certain portions of
the program. Specifically:
* The agency has not yet developed security plans for the licensed
technology and data conversion portions of RSM.
* In addition, agency officials said they do not currently have
detailed security requirements for the licensed technology portion of
RSM, although the request for proposals identified high-level security
requirements. They plan to develop detailed security requirements after
awarding the licensed technology contract to a vendor.
Without fully developed security plans and security requirements for
the licensed technology and data conversion portions of RSM, OPM
increases the risk that both it and its vendors will not meet
information security needs for these portions of the program.
Conclusions:
Billions of dollars of federal employee and annuitant retirement
benefits are dependent on the accuracy and effectiveness of OPM's
retirement systems, but longstanding attempts to modernize these
systems have not materialized.
OPM is currently in the midst of a new effort to modernize its
retirement systems and processes through the acquisition and management
of technology, systems, and services. OPM has made initial efforts to
implement system management processes, including early requirements
development, risk management of tasks in its support contracts, and
plans for establishing effective project management metrics. It has
plans to further define and implement these processes after it awards a
contract for a key segment of RSM.
However, OPM currently lacks many of the sound management processes it
needs to adequately manage this program. Much work remains to be done
to adequately manage requirements, risks, and contracts, and to ensure
that effective security management, process change management, and
executive oversight are in place. Until OPM establishes sound
management processes in these areas, RSM is at increased risk of
overrunning costs, missing milestones, and falling short of promised
performance.
Recommendations:
Systems acquisition management:
Before awarding a contract for the defined benefit technology portion
of RSM, we recommend that the director of OPM ensure that the RSM
program office:
* Conducts a detailed validation of its previously developed
requirements. This includes examining each requirement to determine
whether it is mandatory or optional for the system. OPM should then use
this analysis during contract negotiations to ensure the best value in
awarding the contract.
* Develops project management processes for tracking cost, schedule,
and performance progress on RSM components against planned objectives.
We recommend that the director of OPM ensure that the RSM program
office expeditiously:
* Develops an acquisition strategy that includes deliverables and
milestones throughout the entire project life cycle, addresses issues
related to the transition of the licensed technology to a fully
operational state, and addresses all major elements of RSM.
* Develops an acquisition strategy for the data conversion portion of
RSM that addresses interdependencies with the licensed technology
portion of RSM.
* Develops a list of critical interdependencies among the tasks in
different portions of RSM.
* Implements a comprehensive risk management program including
identification, tracking, and updating of program-wide risks, and
conducts routine discussions of risk mitigation activities with senior
management.
Organizational change management:
We recommend that the director of OPM ensure that the RSM program
office expeditiously updates change management plans to reflect the
current acquisition approach. The plans should identify and address the
tasks and associated milestones needed to prepare users for the impact
of the system on their roles and responsibilities.
IT investment management:
We recommend that the director of OPM ensure that the RSM program
office expeditiously develops a comprehensive governance structure that
includes documented processes guiding the executive steering
committee's activities.
Information security:
We recommend that the director of OPM ensure that the RSM program
office expeditiously develops a detailed security plan and a set of
security requirements for the licensed technology and data conversion
portions of RSM.
Agency Comments and Our Evaluation:
OPM officials, including the RSM program manager, provided us with oral
comments on a draft of this briefing. In their comments, officials
generally agreed with the facts and recommendations in our briefing.
Agency officials stated that their recently hired project management
consultant would help them address our recommendations in systems
acquisition management and investment management. In addition, they
provided suggestions for technical corrections, which we incorporated
in this briefing as appropriate.
Agency officials agreed that analyzing and validating requirements is
important, but disagreed that this needed to be completed before
awarding the licensed technology contract. They stated that they had
previously performed some validation of requirements and revised the
request for proposals for the licensed technology contract to reflect
this. Agency officials also said they were using their understanding of
mandatory and optional requirements during negotiations with potential
vendors; however, they did not provide a clearly defined plan for doing
this.
A clear understanding of optional versus mandatory requirements is
critical to ensuring that the government obtains the best value in its
systems acquisitions. Our review of the request for proposals and other
program documentation does not indicate that OPM has clearly documented
the mandatory versus optional requirements. Since OPM has not fully
determined its essential requirements, the agency may not be able to
select the vendor that can provide the best solution at least cost.
Based on its current approach, OPM will not know the actual cost of
licensing technology until after contract award and the negotiation of
customization costs with the selected vendor.
NOTES:
[1] H. R. Conf. Rep. No. 108-401, at 915 (2003); S. Rep. No. 108-146,
at 162 (2003).
[2] Carnegie Mellon University Software Engineering Institute, Software
Acquisition Capability Maturity Model (Pittsburgh, PA, April 1999) and
Capability Maturity Model-Integration (Pittsburgh, PA, August 2002).
[3] Office of Personnel Management, Performance and Accountability
Report Fiscal Year 2003, (Washington, D.C.: 2003).
[4] Defined benefit plans calculate benefit amounts in advance based on
factors such as salary level and years of service. They are different
than defined contribution plans, in which employees and employers can
contribute to a worker's individual account and benefits are based on
the contributions to the account and the investment gains and losses
that accumulate.
[5] Due to an interim plan created under The Federal Employees
Retirement Contribution Temporary Adjustment Act, almost all new
employees hired after January 1, 1984 are covered by FERS.
[6] Retirement benefits for members of the military and Foreign Service
are not managed through these systems.
[7] Office of Personnel Management Retirement Insurance Service, FERS
Automated Process System, Information Technology Resources Board
Review, (Washington, D.C.: July 16, 1996).
[8] The e-Payroll initiative is a project managed by OPM to improve
federal payroll operations by consolidating existing federal payroll
system providers and simplifying and standardizing policies and
procedures.
[9] For example, see GAO, Information Technology: Architecture Needed
to Guide NASA's Financial Management Modernization, GAO-04-43
(Washington, D.C.: November 21, 2003) and Department of Defense:
Financial and Business Management Transformation Hindered by Long-
standing Problems, GAO-04-941T (Washington, D.C.: July 8, 2004).
[End of slide presentation]
[End of section]
Appendix II: Comments from the Office of Personnel Management:
OFFICE OF THE DIRECTOR:
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT:
WASHINGTON, DC 20415-0001:
The Honorable David M. Walker:
Comptroller General of the United States:
Government Accountability Office:
Washington DC 20548:
Dear Mr. Walker:
Thank you for providing us the opportunity to review and comment on the
Government Accountability Office's draft report, Office of Personnel
Management's Retirement Systems Modernization Program Faces Numerous
Challenges (GAO-05-237). Our staffs met on December 1, 2004 to discuss
OPM comments on the slides used to brief the Subcommittee on
Transportation, Treasury and General Government, Senate Committee on
Appropriation and the Subcommittee on Transportation, Treasury and
Independent Agencies, House Committee on Appropriations on December 8,
2004.
In the report, you make a number of recommendations to strengthen the
processes to provide effective management and oversight of the
Retirement Systems Modernization (RSM) effort. I agree that these
processes are essential to ensure that our complex modernization effort
be accomplished on time, within budget, and meet the expectations of
improved customer service and promised efficiencies. As you know, we
have taken a number of actions to make sure the necessary processes are
in place to improve our management and oversight and will complete
these activities prior to beginning implementation of the major
modernization components. They include:
Strengthen Project Management:
OPM acquired a contract that will provide expert project management
services to supplement current project leadership. We have assessed the
current program management approach, and developed a plan to strengthen
program management and oversight. The Program Management Plan addresses
RSM project management, including the governance, program and project
management roles, processes and reporting, baseline change control,
risk and issue management, and quality assurance.
An ANSI 748-A compliant Earned Value Management System (EVMS) will be
implemented within the RSM program that integrates cost, schedule and
resources using a web-based tool for capturing, managing, and reporting
earned value data. EVMS will be used throughout the entire RSM
program's life cycle. The EVMS will be implemented within 60 days of
the vendor contract award for the Defined Benefits Technology, Paper
Data Conversion, and Technology and Business Transformation Services
contracts.
OPM is committed to ensuring program management processes and
appropriate oversight will be implemented prior to the major
implementation activities of transitioning to the Defined Benefit
Technology and Paper Data Conversion. Within the major components of
the Paper Data Conversion and Defined Benefits Technology, OPM has used
governance structures to provide sound investment information to
decision makers. A copy has been provided of the OPM Information
Technology (IT) Capital Planning and Investment Control Process. This
process was established to meet the goals of ensuring that OPM's major
IT initiatives are appropriately selected and delivered on time and
within budget, and that the processes are consistent with the
requirements specified in Office of Management and Budget Circulars A-
11 and A-1 30. This process will be followed for all IT implementations
of the RSM program.
License Defined Benefits Technology:
A Defined Benefit Technology Solution Request for Proposal (RFP) has
been issued and evaluations were completed on January 6, 2005. We used
two governance structures consisting of decision makers and subject
matter experts to thoroughly assess the proposals. The Source Selection
Evaluation Team contains technical and functional stakeholders and
subject matter experts. This team evaluated the technical rankings,
price information, best technical solution and recommended a vendor.
The Source Selection Advisory Council (SSAC) consists of OPM executives
and external executives from other Federal agencies to bring full
representation to the Retirement Systems Modernization program. The
SSAC will make the final determination as to the best value in the
vendor selection process. The contract award is dependent upon the
Office of Management and Budget funding for this program. The
Implementation, Transition and Business Process Plan will be completed
in May 2005. With the future award of the Defined Benefits Technology
contract, OPM can look forward to providing world class defined
benefits services to all Federal employees and annuitants.
Acquire Paper Data Conversion Contract:
A Request for Proposal (RFP) has been developed to solicit vendors to
image paper documents for active Federal employees and convert
information into electronic data to be used with other retirement
applications. The planned date for the solicitation of the RFP is March
2005, but its determination is dependent upon the successful contract
award of the Defined Benefits Technology solution. The Paper Data
Conversion major component also includes capturing recurring data
feed(s) from agencies and payroll providers, and one-time feeds of
agency historical electronic retirement data. The Paper Data Conversion
Development Plan was completed November 2004, and the Acquisition Plan
is currently being reviewed by key OPM staff. The Requirements
Analysis, Security Architecture, Infrastructure Architecture, Risk and
Risk Mitigation Plans were completed in December 2004.
Acquire Information Technology and Business Transformation Services
Contract:
An Acquisition Plan for the Information Technology and Business
Transformation has been developed and is currently being reviewed by
key OPM staff. The Plan is to acquire vendor support to provide
Business Transformation and Information Technology support services and
products for the Retirement Systems Modernization's existing and future
foundation elements and useful segments. The contract vehicle will be a
single award Blanket Purchase Agreement that will enable OPM to
interface and integrate the Defined Benefits Technology solution and
Paper Data Conversion projects with existing OPM and other Federal
agency applications and systems. The contract is estimated to be
awarded in July 2005. The selected vendor will work to ensure that
OPM's overall business processes and procedures are transformed and
modernized in accordance with the directives mandated for OPM's
Information Technology systems and applications.
OPM included mandatory business requirements in the RFP for the Defined
Benefit Technology and Paper Data Conversion solutions. Upon contract
award, the remaining business requirements will be reviewed to
determine whether the selected technology solutions should be
customized or adopted without change. OPM's goal is to align Federal
retirement administration functionality and goals with those used in
administering private sector pension plans.
Develop an RSM IT Security Plan:
Information security is vital to all of the systems and applications
within the OPM FEA, including RSM. RSM developed a detailed General
Security System Requirements document which serves as the starting
point for all RSM security implementation activities. This document,
incorporating OPM IT Security policies and requirements as well as
appropriate NIST and OMB guidance on information security, is reviewed,
re-validated and updated as appropriate during the requirements
gathering phase of each RSM segment or component. The detailed security
requirements are then used to design the security-architecture for that
segment or component. The three major acquisitions discussed above will
include security requirements that the proposers must agree to and meet
prior to award of the contracts. As RSM components are ready to be
brought on-line, they will go through a rigorous Certification and
Accreditation process, and will be included in OPM's disaster recovery
and Continuation of Operations Plans.
Improve Change Management:
Change management is critical to the successful implementation of
Retirement Systems Modernization. OPM developed a change management
strategy early in the project. The strategy calls for the development
of a detailed change management plan at the beginning of each
implementation. This strategy reduces re-work that occurs when change
management plans are developed too early in the implementation cycle.
In preparation and recognition of the importance of change management.
RSM recently hired an employee to lead this effort.
In summary, we are committed to the successful implementation of the
Retirement Systems Modernization initiative. We will strengthen our
project management and oversight prior to beginning major
implementation and will continue to look for opportunities to maximize
our success as we implement the major components over the next several
years. We appreciate your support in helping us attain these goals.
Sincerely,
Signed by:
Kay Coles James:
Director:
[End of section]
FOOTNOTES
[1] H.R. Conf. Rep. No. 108-401, at 915 (2003); S. Rep. No. 108-146, at
162 (2003).
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